Herman v. Commissioner
United States Tax Court
Due to the high cost and unavailability of medical malpractice insurance, a physician-owned insurance company known as the Medical Inter-Insurance Exchange of New Jersey (Exchange) was formed in 1976. In order to provide a surplus of funds, physicians or their professional corporations (P.C.'s) provided initial funding. A subordinated loan certificate (SLC) was issued by the Exchange in the name of individual physicians in return for these payments.
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Due to the high cost and unavailability of medical malpractice insurance, a physician-owned insurance company known as the Medical Inter-Insurance Exchange of New Jersey (Exchange) was formed in 1976. In order to provide a surplus of funds, physicians or their professional corporations (P.C.'s) provided initial funding. A subordinated loan certificate (SLC) was issued by the Exchange in the name of individual physicians in return for these payments. The SLC would be redeemed by the Exchange when the physician ceased practicing medicine in New Jersey. Where a P.C. paid for the SLC on behalf of…
1Opinion of the Court
Carl Herman and Harriett Herman, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Herman v. Commissioner
Docket Nos. 344-82, 345-82, 347-82, 450-82, 709-82, 715-82, 746-82, 751-82, 1753-82, 2019-82, 2597-82, 9154-82, 9161-82, 14689-82
United States Tax Court
84 T.C. 120; 1985 U.S. Tax Ct. LEXIS 130; 84 T.C. No. 8;
January 30, 1985. January 30, 1985, Filed
Decisions will be entered for the petitioners in docket Nos. 344-82, 345-82, 347-82, 450-82, 709-82, 715-82, 746-82, 751-82, 2597-82, 9161-82, and 14689-82.
Decisions will be entered for the respondent in docket Nos. 1753-82…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
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